Federal Program Information: Annual Appropriation Supplemental Funding (ALN: 84.915A) and Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - When awards provide for advance payments, recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement. Cash advances to a recipient organization shall be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the recipient organization in carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the recipient organization for direct program or project costs. C. Cash Management ? Education Stabilization Fund ? ESF requires that Student Aid Portion should be disbursed within 15 calendar days of the drawdown from ED?s G5 grants system and Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Questioned Costs: None. Context: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Effect or Potential Effect: The University is not properly following its established policies and procedures to ensure that compliance is maintained with respect to the Cash Management compliance requirements. Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls to comply with the Cash Management requirements associated with is drawdowns of federal funds. Views of Responsible Officials: The original lost revenue calculation was completed by the Deputy Chief Financial Officer in August 2021. The calculation was reviewed by the Controller and Assistant Treasurer prior to drawing funds. The lost revenue calculation was compiled by management before the draw was completed on 09/09/2021. Deloitte was contracted for an additional review of the lost revenue increasing the lost revenue from $23M to $29M. Howard University will continue to comply with cash management policies and procedures in accordance with ALN: 84.915A.
Federal Program Information: Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (?FFEL?) loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: ? For 10 of 40 campus level records tested, the University did not certify the students? enrollment data within 60 days. ? For 4 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. ? For 6 of 40 campus level records tested, the University did not accurately report the students? enrollment status. ? For 2 of 25 program level records tested, the University did not notify the Department of the students? graduated status. ? For 4 of 25 program level records tested, the University did not accurately report the students? enrollment status. ? Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2022 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the Office of the Registrar (Registrar), which is responsible for providing enrollment reports to Howard University?s third-party servicer, National Student Clearinghouse (NSC), who then submits the report to the National Student Loan Data System (NSLDS). The departure of a key registrar personnel resulted in miscommunication and neglect of the enrollment reporting duties. The issue has since been remedied, but due to the time lag, will take an additional fiscal year for improvements to be observed.
Federal Program Information: Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (?FFEL?) loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: ? For 10 of 40 campus level records tested, the University did not certify the students? enrollment data within 60 days. ? For 4 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. ? For 6 of 40 campus level records tested, the University did not accurately report the students? enrollment status. ? For 2 of 25 program level records tested, the University did not notify the Department of the students? graduated status. ? For 4 of 25 program level records tested, the University did not accurately report the students? enrollment status. ? Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2022 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the Office of the Registrar (Registrar), which is responsible for providing enrollment reports to Howard University?s third-party servicer, National Student Clearinghouse (NSC), who then submits the report to the National Student Loan Data System (NSLDS). The departure of a key registrar personnel resulted in miscommunication and neglect of the enrollment reporting duties. The issue has since been remedied, but due to the time lag, will take an additional fiscal year for improvements to be observed.
Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Certain parent PLUS loan borrowers were not notified of loan disbursements to their dependent?s account. Additionally, the University was unable to provide documentation evidencing that notifications were sent to certain borrowers. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: The University is not in compliance with loan disbursement notification requirements. Questioned Costs: None. 118 Context: ? For 6 of 40 students selected for testing who received a Federal Direct PLUS loan, while the University notified the student within the required timeframe, notification was not sent to the parent borrower as required. ? For 2 of 40 students selected for testing, the University was unable to provide documentation confirming that a notification was sent and thus, we were unable to determine whether notifications were made within the required timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005. Recommendation: We recommend the University enhance its procedures and internal controls over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe. Views of Responsible Officials: Loan disbursement notifications are now the responsibility of the Office of Financial Aid (Financial Aid). Notifications are now being sent out through Ellucian Banner (Banner) when a student has been awarded. The disbursement notification documentation is now electronic and does not require manual actions from Howard University employees to be completed. The following areas identified in the audit have been addressed: ? Notifications are immediately sent out electronically when the student is awarded, allowing Howard to meet the required notification timeline for notification. ? Each notification is addressed to the specific person (i.e., parent, student) who is responsible for paying back the loan. ? The name of the student, exact amount of the disbursement and the date of disbursement is generated on the notification as well. Bi-semester reviews have been completed by the Associate Director for Compliance (Financial Aid) to ensure the loan disbursement notifications are being generated in the required timeline and includes all federally required information listed above in each notification. Spring 2022, Summer 2022, and Fall 2022 reviews have been completed thus far with no significant issues identified. The policies and procedures for loan disbursement notifications were updated in April 2022. These will be reviewed annually.
Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: None. Context: Several instances of Federal Direct Loan funds drawn and held in excess of the allowable time frame were identified throughout the University?s fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-006. Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education. Views of Responsible Officials: The finance and financial aid divisions will collaborate to improve the internal controls that are in place to ensure there is a three-day turnaround for draws and refunds. The policies and procedures for cash management were updated in July 2022.
Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 1 of 25 students selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV credit balances are paid timely to students. Views of Responsible Officials: There was one credit balance in the sample (from September 2021) that was not processed within 14 days. It was completed on the 20th day after the refund was created on the student?s account. Note that the record identified in the sample was during the time of the cyberattack. While this does not absolve Howard of demonstration of administrative capability, the bursar team could not have performed their function during this time.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Education Stabilization Fund (?ESF?) (ALN: 84.425E and 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - There are three components to reporting for ESF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Institutions must report publicly on their primary websites on a quarterly basis for both student portion and institutional portion funds. Condition: The University did not appropriately prepare their ESF quarterly reports during the year ended June 30, 2022. Quarterly reports were also not posted to the University?s website timely. Additionally, the University was unable to provide documentation supporting that the ESF annual report was submitted as required. Cause: Insufficient internal controls and administrative oversight with respect to Reporting requirements. Effect or Potential Effect: The University did not comply with the requirements of Reporting. Questioned Costs: None. Context: We noted the following exceptions: ? For 2 of 2 quarters selected for testing, the University did not prepare certain ESF Institutional Portion quarterly reports using the appropriate reporting form. Additionally, the University was unable to provide documentation supporting that quarterly reporting information was posted to the University?s website within 10 days of each quarter end. ? For 2 of 2 quarters selected for testing, the University?s quarterly public reporting of its Student Aid Portion expenditures did not include information identified as key by the Department. ? The University was unable to provide documentation supporting the accurate and timely submission of the ESF annual report. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-012. Recommendation: We recommend the University enhance its procedures and internal controls over the applicable ESF reporting requirements to ensure reports are submitted timely and accurately. Views of Responsible Officials: On March 21, 2023, Howard assigned Ms. Sammara Evans, the Director of Institutional Research, as the lead for quarterly and annual HEERF reporting. The areas with access to the information required to complete the quarterly and annual HEERF reporting have now been added to the Education Stabilization Fund (ESF) site as editors. This list of editors on the ESF site includes representatives from the Financial Aid Office, the Bursar?s Office, Enrollment Analytics and Grants & Contracts. These offices can now receive notifications regarding submission deadlines and have access to update the information for each report. Prior to the quarterly or annual report due date, the Director of Institutional Research will request the necessary information from each department and is aware of her responsibilities to do so. HEERF reporting responsibilities have been defined.
Federal Program Information: Education Stabilization Fund (?ESF?) (ALN: 84.425E and 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - There are three components to reporting for ESF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Institutions must report publicly on their primary websites on a quarterly basis for both student portion and institutional portion funds. Condition: The University did not appropriately prepare their ESF quarterly reports during the year ended June 30, 2022. Quarterly reports were also not posted to the University?s website timely. Additionally, the University was unable to provide documentation supporting that the ESF annual report was submitted as required. Cause: Insufficient internal controls and administrative oversight with respect to Reporting requirements. Effect or Potential Effect: The University did not comply with the requirements of Reporting. Questioned Costs: None. Context: We noted the following exceptions: ? For 2 of 2 quarters selected for testing, the University did not prepare certain ESF Institutional Portion quarterly reports using the appropriate reporting form. Additionally, the University was unable to provide documentation supporting that quarterly reporting information was posted to the University?s website within 10 days of each quarter end. ? For 2 of 2 quarters selected for testing, the University?s quarterly public reporting of its Student Aid Portion expenditures did not include information identified as key by the Department. ? The University was unable to provide documentation supporting the accurate and timely submission of the ESF annual report. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-012. Recommendation: We recommend the University enhance its procedures and internal controls over the applicable ESF reporting requirements to ensure reports are submitted timely and accurately. Views of Responsible Officials: On March 21, 2023, Howard assigned Ms. Sammara Evans, the Director of Institutional Research, as the lead for quarterly and annual HEERF reporting. The areas with access to the information required to complete the quarterly and annual HEERF reporting have now been added to the Education Stabilization Fund (ESF) site as editors. This list of editors on the ESF site includes representatives from the Financial Aid Office, the Bursar?s Office, Enrollment Analytics and Grants & Contracts. These offices can now receive notifications regarding submission deadlines and have access to update the information for each report. Prior to the quarterly or annual report due date, the Director of Institutional Research will request the necessary information from each department and is aware of her responsibilities to do so. HEERF reporting responsibilities have been defined.
Federal Program Information: Annual Appropriation Supplemental Funding (ALN: 84.915A) and Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - When awards provide for advance payments, recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement. Cash advances to a recipient organization shall be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the recipient organization in carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the recipient organization for direct program or project costs. C. Cash Management ? Education Stabilization Fund ? ESF requires that Student Aid Portion should be disbursed within 15 calendar days of the drawdown from ED?s G5 grants system and Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Questioned Costs: None. Context: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Effect or Potential Effect: The University is not properly following its established policies and procedures to ensure that compliance is maintained with respect to the Cash Management compliance requirements. Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls to comply with the Cash Management requirements associated with is drawdowns of federal funds. Views of Responsible Officials: The original lost revenue calculation was completed by the Deputy Chief Financial Officer in August 2021. The calculation was reviewed by the Controller and Assistant Treasurer prior to drawing funds. The lost revenue calculation was compiled by management before the draw was completed on 09/09/2021. Deloitte was contracted for an additional review of the lost revenue increasing the lost revenue from $23M to $29M. Howard University will continue to comply with cash management policies and procedures in accordance with ALN: 84.915A.
Federal Program Information: Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed - ESF Institutional Portion funds may be used to defray expenses associated with coronavirus (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll) and to make additional financial grants to students. ESF funds may also have been used to carry out student support activities authorized by the HEA that address needs related to coronavirus. Construction and Real Property Expenditures under ESF (a)(2) subprograms: Under the Consolidated Appropriations Act, 2022, as of March 15, 2022, ESF (a)(2) program subgrantees may expend their ESF (a)(2) grant funds on construction and real property for projects that are connected to the purpose of the ESF program to ?prevent, prepare for, and respond to coronavirus.? Any ESF (a)(2) grantees taking advantage of this flexibility will have to receive approval from the Department of Education for their specific construction and real property projects supported by ESF (a)(2) grant funds. ESF (a)(2) grantees cannot use their (a)(2) grant funds on construction or real property associated with facilities related to athletics, sectarian instruction, or religious worship. B. Allowable Costs/Cost Principles - Grantees are prohibited from using ESF funding for the acquisition of real property or construction. This includes using ESF grant funds on capital projects, including deferred maintenance and capital improvement. However, this general prohibition on construction and acquisition of real property does not extend to activities that meet the definition of ?minor remodeling?. Minor remodeling means minor alterations in a previously completed building, for purposes associated with the coronavirus. The term also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building. The term does not include permanent building construction, structural alterations to buildings, building maintenance, or repairs. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Indeterminable. Context: 1 of 40 ESF Institutional Portion expenditures selected for testing were not allowable under the federal award as they were used for construction, maintenance and/or repairs. The University was unable to provide supporting documentation that these costs were specifically connected to purposes associated with the coronavirus and/or that approval was received from the Department of Education prior to disbursement. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-013. Recommendation: We recommend that the University enhance its internal controls and procedures surrounding the review of expenditures charged to federal grants to ensure expenditures are allowable under the federal awards. Views of Responsible Officials: Grants and Contracts will implement a two-tier review process to ensure expenditures charged to the HEERF grant are allowable and in accordance with the Department of Education policies and procedures. Additionally, any expenditures requested and/or transferred to the HEERF grant will require the two-tier review/approval process.
Federal Program Information: Provider Relief Fund (ALN: 93.438) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Per Uniform Guidance, ?200.510(b), the auditee shall prepare a schedule of expenditures of Federal awards (the ?Schedule?) for the period covered by the auditee's financial statements. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the Schedule easier to use. At a minimum, the Schedule should list individual Federal programs by Federal agency and provide total Federal awards expended for each Federal program during the entity?s fiscal year. Condition: During our audit procedures, we noted that the University did not complete the Schedule timely, and it was also not properly reviewed by management prior to being provided for audit purposes. Cause: Insufficient internal controls and administrative oversight with respect to the timely preparation and review of Schedule. Effect or Potential Effect: Lack of appropriate and timely review by management increases the risk that the amounts, contract, or grant names, Assistance Listing Number (?ALN?) information, and classification of the awards presented on the Schedule are presented incorrectly. Questioned Costs: None. Context: The initial Schedule received excluded certain federal expenditures related to the Provider Relief Fund that were applicable to the year ended June 30, 2022. The exclusion of this federal program was due to insufficient administrative oversight as well as a lack of communication and coordination between the University and its subsidiary, Howard University Hospital (the ?Hospital?). The inclusion of these expenditures on the current year SEFA resulted in an additional major program that was required to be tested. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University implement additional internal controls and enhance their current policies and procedures to enable grants and contracts personnel to effectively maintain a detailed Schedule that contains the correct amounts, contract or grants names, ALN information and classification of the awards, which can be more readily reconciled to the underlying general ledger detail prior to receipt by the auditors. We also recommend that grants and contracts personnel at the University have frequent communication with the applicable Hospital personnel to ensure that all federal expenditures incurred and federal awards received during the year are appropriately reflected within the Schedule as required. Views of Responsible Officials: The Office of Grants and Contracts will update the policies and procedures to include a detailed, timely and accurate submission of federal expenditures in accordance with the Uniform Guidance, ?200.510(b) to reflect on the annual SEFA. Quarterly meetings and annual reviews will be established with appropriate Howard University Hospitals? personnel to ensure required expenditures are included on the SEFA per federal requirements. Sr. Director of Grants and Contracts and the Controller will prepare the SEFA going forward and will receive formal approval by the Controller.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs ? In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: $29,909. Context: For 1 of 25 Health Workforce for the 21st Century expenditures selected for testing, costs charged to the federal award were erroneously duplicated. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls surrounding review of expenditures charged to federal grants to ensure expenditures are allowable based on the grant agreement and federal regulations. Views of Responsible Officials: The Controller?s Office and Grants and Contracts will work with Accounts Payable to ensure that payments to vendors are applied timely in Workday. Accounts payable will be required to review all wire requests to ensure the invoices have not been previously paid by check prior to initiating wires.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Annual Appropriation Supplemental Funding (ALN: 84.915A) and Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - When awards provide for advance payments, recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement. Cash advances to a recipient organization shall be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the recipient organization in carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the recipient organization for direct program or project costs. C. Cash Management ? Education Stabilization Fund ? ESF requires that Student Aid Portion should be disbursed within 15 calendar days of the drawdown from ED?s G5 grants system and Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Questioned Costs: None. Context: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Effect or Potential Effect: The University is not properly following its established policies and procedures to ensure that compliance is maintained with respect to the Cash Management compliance requirements. Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls to comply with the Cash Management requirements associated with is drawdowns of federal funds. Views of Responsible Officials: The original lost revenue calculation was completed by the Deputy Chief Financial Officer in August 2021. The calculation was reviewed by the Controller and Assistant Treasurer prior to drawing funds. The lost revenue calculation was compiled by management before the draw was completed on 09/09/2021. Deloitte was contracted for an additional review of the lost revenue increasing the lost revenue from $23M to $29M. Howard University will continue to comply with cash management policies and procedures in accordance with ALN: 84.915A.
Federal Program Information: Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (?FFEL?) loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: ? For 10 of 40 campus level records tested, the University did not certify the students? enrollment data within 60 days. ? For 4 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. ? For 6 of 40 campus level records tested, the University did not accurately report the students? enrollment status. ? For 2 of 25 program level records tested, the University did not notify the Department of the students? graduated status. ? For 4 of 25 program level records tested, the University did not accurately report the students? enrollment status. ? Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2022 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the Office of the Registrar (Registrar), which is responsible for providing enrollment reports to Howard University?s third-party servicer, National Student Clearinghouse (NSC), who then submits the report to the National Student Loan Data System (NSLDS). The departure of a key registrar personnel resulted in miscommunication and neglect of the enrollment reporting duties. The issue has since been remedied, but due to the time lag, will take an additional fiscal year for improvements to be observed.
Federal Program Information: Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (?FFEL?) loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: ? For 10 of 40 campus level records tested, the University did not certify the students? enrollment data within 60 days. ? For 4 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. ? For 6 of 40 campus level records tested, the University did not accurately report the students? enrollment status. ? For 2 of 25 program level records tested, the University did not notify the Department of the students? graduated status. ? For 4 of 25 program level records tested, the University did not accurately report the students? enrollment status. ? Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2022 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the Office of the Registrar (Registrar), which is responsible for providing enrollment reports to Howard University?s third-party servicer, National Student Clearinghouse (NSC), who then submits the report to the National Student Loan Data System (NSLDS). The departure of a key registrar personnel resulted in miscommunication and neglect of the enrollment reporting duties. The issue has since been remedied, but due to the time lag, will take an additional fiscal year for improvements to be observed.
Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Certain parent PLUS loan borrowers were not notified of loan disbursements to their dependent?s account. Additionally, the University was unable to provide documentation evidencing that notifications were sent to certain borrowers. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: The University is not in compliance with loan disbursement notification requirements. Questioned Costs: None. 118 Context: ? For 6 of 40 students selected for testing who received a Federal Direct PLUS loan, while the University notified the student within the required timeframe, notification was not sent to the parent borrower as required. ? For 2 of 40 students selected for testing, the University was unable to provide documentation confirming that a notification was sent and thus, we were unable to determine whether notifications were made within the required timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005. Recommendation: We recommend the University enhance its procedures and internal controls over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe. Views of Responsible Officials: Loan disbursement notifications are now the responsibility of the Office of Financial Aid (Financial Aid). Notifications are now being sent out through Ellucian Banner (Banner) when a student has been awarded. The disbursement notification documentation is now electronic and does not require manual actions from Howard University employees to be completed. The following areas identified in the audit have been addressed: ? Notifications are immediately sent out electronically when the student is awarded, allowing Howard to meet the required notification timeline for notification. ? Each notification is addressed to the specific person (i.e., parent, student) who is responsible for paying back the loan. ? The name of the student, exact amount of the disbursement and the date of disbursement is generated on the notification as well. Bi-semester reviews have been completed by the Associate Director for Compliance (Financial Aid) to ensure the loan disbursement notifications are being generated in the required timeline and includes all federally required information listed above in each notification. Spring 2022, Summer 2022, and Fall 2022 reviews have been completed thus far with no significant issues identified. The policies and procedures for loan disbursement notifications were updated in April 2022. These will be reviewed annually.
Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: None. Context: Several instances of Federal Direct Loan funds drawn and held in excess of the allowable time frame were identified throughout the University?s fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-006. Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education. Views of Responsible Officials: The finance and financial aid divisions will collaborate to improve the internal controls that are in place to ensure there is a three-day turnaround for draws and refunds. The policies and procedures for cash management were updated in July 2022.
Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 1 of 25 students selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV credit balances are paid timely to students. Views of Responsible Officials: There was one credit balance in the sample (from September 2021) that was not processed within 14 days. It was completed on the 20th day after the refund was created on the student?s account. Note that the record identified in the sample was during the time of the cyberattack. While this does not absolve Howard of demonstration of administrative capability, the bursar team could not have performed their function during this time.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Education Stabilization Fund (?ESF?) (ALN: 84.425E and 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - There are three components to reporting for ESF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Institutions must report publicly on their primary websites on a quarterly basis for both student portion and institutional portion funds. Condition: The University did not appropriately prepare their ESF quarterly reports during the year ended June 30, 2022. Quarterly reports were also not posted to the University?s website timely. Additionally, the University was unable to provide documentation supporting that the ESF annual report was submitted as required. Cause: Insufficient internal controls and administrative oversight with respect to Reporting requirements. Effect or Potential Effect: The University did not comply with the requirements of Reporting. Questioned Costs: None. Context: We noted the following exceptions: ? For 2 of 2 quarters selected for testing, the University did not prepare certain ESF Institutional Portion quarterly reports using the appropriate reporting form. Additionally, the University was unable to provide documentation supporting that quarterly reporting information was posted to the University?s website within 10 days of each quarter end. ? For 2 of 2 quarters selected for testing, the University?s quarterly public reporting of its Student Aid Portion expenditures did not include information identified as key by the Department. ? The University was unable to provide documentation supporting the accurate and timely submission of the ESF annual report. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-012. Recommendation: We recommend the University enhance its procedures and internal controls over the applicable ESF reporting requirements to ensure reports are submitted timely and accurately. Views of Responsible Officials: On March 21, 2023, Howard assigned Ms. Sammara Evans, the Director of Institutional Research, as the lead for quarterly and annual HEERF reporting. The areas with access to the information required to complete the quarterly and annual HEERF reporting have now been added to the Education Stabilization Fund (ESF) site as editors. This list of editors on the ESF site includes representatives from the Financial Aid Office, the Bursar?s Office, Enrollment Analytics and Grants & Contracts. These offices can now receive notifications regarding submission deadlines and have access to update the information for each report. Prior to the quarterly or annual report due date, the Director of Institutional Research will request the necessary information from each department and is aware of her responsibilities to do so. HEERF reporting responsibilities have been defined.
Federal Program Information: Education Stabilization Fund (?ESF?) (ALN: 84.425E and 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - There are three components to reporting for ESF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Institutions must report publicly on their primary websites on a quarterly basis for both student portion and institutional portion funds. Condition: The University did not appropriately prepare their ESF quarterly reports during the year ended June 30, 2022. Quarterly reports were also not posted to the University?s website timely. Additionally, the University was unable to provide documentation supporting that the ESF annual report was submitted as required. Cause: Insufficient internal controls and administrative oversight with respect to Reporting requirements. Effect or Potential Effect: The University did not comply with the requirements of Reporting. Questioned Costs: None. Context: We noted the following exceptions: ? For 2 of 2 quarters selected for testing, the University did not prepare certain ESF Institutional Portion quarterly reports using the appropriate reporting form. Additionally, the University was unable to provide documentation supporting that quarterly reporting information was posted to the University?s website within 10 days of each quarter end. ? For 2 of 2 quarters selected for testing, the University?s quarterly public reporting of its Student Aid Portion expenditures did not include information identified as key by the Department. ? The University was unable to provide documentation supporting the accurate and timely submission of the ESF annual report. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-012. Recommendation: We recommend the University enhance its procedures and internal controls over the applicable ESF reporting requirements to ensure reports are submitted timely and accurately. Views of Responsible Officials: On March 21, 2023, Howard assigned Ms. Sammara Evans, the Director of Institutional Research, as the lead for quarterly and annual HEERF reporting. The areas with access to the information required to complete the quarterly and annual HEERF reporting have now been added to the Education Stabilization Fund (ESF) site as editors. This list of editors on the ESF site includes representatives from the Financial Aid Office, the Bursar?s Office, Enrollment Analytics and Grants & Contracts. These offices can now receive notifications regarding submission deadlines and have access to update the information for each report. Prior to the quarterly or annual report due date, the Director of Institutional Research will request the necessary information from each department and is aware of her responsibilities to do so. HEERF reporting responsibilities have been defined.
Federal Program Information: Annual Appropriation Supplemental Funding (ALN: 84.915A) and Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - When awards provide for advance payments, recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement. Cash advances to a recipient organization shall be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the recipient organization in carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the recipient organization for direct program or project costs. C. Cash Management ? Education Stabilization Fund ? ESF requires that Student Aid Portion should be disbursed within 15 calendar days of the drawdown from ED?s G5 grants system and Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Questioned Costs: None. Context: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Effect or Potential Effect: The University is not properly following its established policies and procedures to ensure that compliance is maintained with respect to the Cash Management compliance requirements. Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls to comply with the Cash Management requirements associated with is drawdowns of federal funds. Views of Responsible Officials: The original lost revenue calculation was completed by the Deputy Chief Financial Officer in August 2021. The calculation was reviewed by the Controller and Assistant Treasurer prior to drawing funds. The lost revenue calculation was compiled by management before the draw was completed on 09/09/2021. Deloitte was contracted for an additional review of the lost revenue increasing the lost revenue from $23M to $29M. Howard University will continue to comply with cash management policies and procedures in accordance with ALN: 84.915A.
Federal Program Information: Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed - ESF Institutional Portion funds may be used to defray expenses associated with coronavirus (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll) and to make additional financial grants to students. ESF funds may also have been used to carry out student support activities authorized by the HEA that address needs related to coronavirus. Construction and Real Property Expenditures under ESF (a)(2) subprograms: Under the Consolidated Appropriations Act, 2022, as of March 15, 2022, ESF (a)(2) program subgrantees may expend their ESF (a)(2) grant funds on construction and real property for projects that are connected to the purpose of the ESF program to ?prevent, prepare for, and respond to coronavirus.? Any ESF (a)(2) grantees taking advantage of this flexibility will have to receive approval from the Department of Education for their specific construction and real property projects supported by ESF (a)(2) grant funds. ESF (a)(2) grantees cannot use their (a)(2) grant funds on construction or real property associated with facilities related to athletics, sectarian instruction, or religious worship. B. Allowable Costs/Cost Principles - Grantees are prohibited from using ESF funding for the acquisition of real property or construction. This includes using ESF grant funds on capital projects, including deferred maintenance and capital improvement. However, this general prohibition on construction and acquisition of real property does not extend to activities that meet the definition of ?minor remodeling?. Minor remodeling means minor alterations in a previously completed building, for purposes associated with the coronavirus. The term also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building. The term does not include permanent building construction, structural alterations to buildings, building maintenance, or repairs. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Indeterminable. Context: 1 of 40 ESF Institutional Portion expenditures selected for testing were not allowable under the federal award as they were used for construction, maintenance and/or repairs. The University was unable to provide supporting documentation that these costs were specifically connected to purposes associated with the coronavirus and/or that approval was received from the Department of Education prior to disbursement. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-013. Recommendation: We recommend that the University enhance its internal controls and procedures surrounding the review of expenditures charged to federal grants to ensure expenditures are allowable under the federal awards. Views of Responsible Officials: Grants and Contracts will implement a two-tier review process to ensure expenditures charged to the HEERF grant are allowable and in accordance with the Department of Education policies and procedures. Additionally, any expenditures requested and/or transferred to the HEERF grant will require the two-tier review/approval process.
Federal Program Information: Provider Relief Fund (ALN: 93.438) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Per Uniform Guidance, ?200.510(b), the auditee shall prepare a schedule of expenditures of Federal awards (the ?Schedule?) for the period covered by the auditee's financial statements. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the Schedule easier to use. At a minimum, the Schedule should list individual Federal programs by Federal agency and provide total Federal awards expended for each Federal program during the entity?s fiscal year. Condition: During our audit procedures, we noted that the University did not complete the Schedule timely, and it was also not properly reviewed by management prior to being provided for audit purposes. Cause: Insufficient internal controls and administrative oversight with respect to the timely preparation and review of Schedule. Effect or Potential Effect: Lack of appropriate and timely review by management increases the risk that the amounts, contract, or grant names, Assistance Listing Number (?ALN?) information, and classification of the awards presented on the Schedule are presented incorrectly. Questioned Costs: None. Context: The initial Schedule received excluded certain federal expenditures related to the Provider Relief Fund that were applicable to the year ended June 30, 2022. The exclusion of this federal program was due to insufficient administrative oversight as well as a lack of communication and coordination between the University and its subsidiary, Howard University Hospital (the ?Hospital?). The inclusion of these expenditures on the current year SEFA resulted in an additional major program that was required to be tested. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University implement additional internal controls and enhance their current policies and procedures to enable grants and contracts personnel to effectively maintain a detailed Schedule that contains the correct amounts, contract or grants names, ALN information and classification of the awards, which can be more readily reconciled to the underlying general ledger detail prior to receipt by the auditors. We also recommend that grants and contracts personnel at the University have frequent communication with the applicable Hospital personnel to ensure that all federal expenditures incurred and federal awards received during the year are appropriately reflected within the Schedule as required. Views of Responsible Officials: The Office of Grants and Contracts will update the policies and procedures to include a detailed, timely and accurate submission of federal expenditures in accordance with the Uniform Guidance, ?200.510(b) to reflect on the annual SEFA. Quarterly meetings and annual reviews will be established with appropriate Howard University Hospitals? personnel to ensure required expenditures are included on the SEFA per federal requirements. Sr. Director of Grants and Contracts and the Controller will prepare the SEFA going forward and will receive formal approval by the Controller.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs ? In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: $29,909. Context: For 1 of 25 Health Workforce for the 21st Century expenditures selected for testing, costs charged to the federal award were erroneously duplicated. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls surrounding review of expenditures charged to federal grants to ensure expenditures are allowable based on the grant agreement and federal regulations. Views of Responsible Officials: The Controller?s Office and Grants and Contracts will work with Accounts Payable to ensure that payments to vendors are applied timely in Workday. Accounts payable will be required to review all wire requests to ensure the invoices have not been previously paid by check prior to initiating wires.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.
Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.
Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.