Audit 3886

Information on the Major Federal Program - Federal Agency: National Science Foundation Assistance Listing Number: 47.076 Assistance Listing Name: Research and Development Cluster Award Number: 2120006 Award Period: 7/1/2022 – 6/30/2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “FFATA” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to identify awards subject to FFATA, collect and report information on each first tier subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition - During our testing of FFATA reporting requirements, we noted for 2 subrecipients tested, there was no action taken to perform the mandatory FFATA reporting requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 2 2 2 Not applicable – not tested Not applicable – not tested Dollar Amount of Tested 2023 Subawards Transactions Subawards Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $143,838 $807,704 $807,704 Not applicable – not tested Not applicable – not tested Cause – The Company does not have adequate policies and procedures in place to ensure compliance with the requirements regarding FFATA reporting. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance with laws and regulations. Questioned costs – None. Context - This is a condition identified based upon our review of the Company’s compliance with specified FFATA reporting requirements. The sample was selected based on a non-statistical basis. The prevalence of this finding is detailed in the condition section above. Repeat Finding – This is not a repeat finding. Recommendation - BDO recommends that the Company establish policies and procedures to ensure that the required information is collected and reported in the FFATA Subaward Reporting System. Views of Responsible Officials - Management agrees with the auditor’s comments, and the following action has been implemented to ensure that the required information is collected and reported timely in the FFATA Subaward Reporting System (FSRS). Beginning in the fiscal year 2024, the Company implemented a formal policy and procedure to file a FFATA subaward report by the end of the month following the month in which they award any sub-grant or amendment equal to or greater than $30,000 in federal funds. The Company has completed and filed the required FFATA Subaward reporting for those subgrants equal to or greater than $30,000 in federal funds and is current with the required reporting as of November 2023 and will monitor future subgrants of federal funds in order to comply with the reporting.

Information on the Major Federal Program - Federal Agency: National Science Foundation Assistance Listing Number: 47.076 Assistance Listing Name: Research and Development Cluster Award Number: 2120006 Award Period: 7/1/2022 – 6/30/2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “FFATA” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to identify awards subject to FFATA, collect and report information on each first tier subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition - During our testing of FFATA reporting requirements, we noted for 2 subrecipients tested, there was no action taken to perform the mandatory FFATA reporting requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 2 2 2 Not applicable – not tested Not applicable – not tested Dollar Amount of Tested 2023 Subawards Transactions Subawards Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $143,838 $807,704 $807,704 Not applicable – not tested Not applicable – not tested Cause – The Company does not have adequate policies and procedures in place to ensure compliance with the requirements regarding FFATA reporting. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance with laws and regulations. Questioned costs – None. Context - This is a condition identified based upon our review of the Company’s compliance with specified FFATA reporting requirements. The sample was selected based on a non-statistical basis. The prevalence of this finding is detailed in the condition section above. Repeat Finding – This is not a repeat finding. Recommendation - BDO recommends that the Company establish policies and procedures to ensure that the required information is collected and reported in the FFATA Subaward Reporting System. Views of Responsible Officials - Management agrees with the auditor’s comments, and the following action has been implemented to ensure that the required information is collected and reported timely in the FFATA Subaward Reporting System (FSRS). Beginning in the fiscal year 2024, the Company implemented a formal policy and procedure to file a FFATA subaward report by the end of the month following the month in which they award any sub-grant or amendment equal to or greater than $30,000 in federal funds. The Company has completed and filed the required FFATA Subaward reporting for those subgrants equal to or greater than $30,000 in federal funds and is current with the required reporting as of November 2023 and will monitor future subgrants of federal funds in order to comply with the reporting.